Case law

BROWN v. COMMISSIONER

2005 T.C. Summary Opinion 155 · United States Tax Court · Oct 20, 2005

BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8242-04S. Filed October 20, 2005. Matthew P. Brown, pro se. Michael R. … Vanicek v. Commissioner, 85 T.C. 731, 743 (1985). Section 274(d) supersedes the general rule of Cohan v.

BROWN v. COMMISSIONER

2005 T.C. Summary Opinion 85 · United States Tax Court · Jun 16, 2005

BROWN, JR. AND LINDA L. BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18198-03S. Filed June 16, 2005. Charles A. Brown, Jr., for petitioners. … See Murata v. Commissioner, supra; Golden v. Commissioner, supra. Mr. Brown testified that 25 percent of his home’s local telephone service was used for his law practice.

Royal Crown Bottling Co. v. Commissioner

22 T.C. 688 · United States Tax Court · Jun 30, 1954

Royal Crown Bottling Company of Knoxville, Petitioner, v. Commissioner of Internal Revenue, Respondent Royal Crown Bottling Co. v. Commissioner Docket No. 21881 * United States Tax Court 22 T.C. 688 ; 1954 U.S. Tax Ct. … Brown was elected president and a member of the board of directors of Chero Cola Bottling Company on February 16, 1938.

Longview Hilton Hotel Co. v. Commissioner

9 T.C. 180 · United States Tax Court · Aug 14, 1947

BROWN v. COMMISSIONER

2005 T.C. Summary Opinion 37 · United States Tax Court · Mar 30, 2005

Summary Opinion 2005-37 UNITED STATES TAX COURT LIONEL BROWN, Petitioner v. … Sego v. Commissioner, supra at 610; Goza v. Commissioner, 114 T.C. 176, 181 (2000).

GREEN v. COMMISSIONER

3 T.C. 74 · United States Tax Court · Jan 19, 1944

In Scripps v. Commissioner (C. C. … Brown, 1 T. C. 225 ; and Jones v. Hassett, 45 Fed. Supp. 195.

Central Bank Co. v. Commissioner

39 T.C. 856 · United States Tax Court · Mar 14, 1963

As was pointed out by the Board of Tax Appeals in John I. … Altschul Tobacco Co. v. Commissioner, 42 Fed. (2d) 609.

BROWN v. COMMISSIONER

2004 T.C. Summary Opinion 109 · United States Tax Court · Aug 10, 2004

BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16142-03S. Filed August 10, 2004. Yakuba G. Brown, pro se. Hieu C. Nguyen, for respondent. … Fernandez v. Commissioner, 114 T.C. 324, 328 (2000); Naftel v.

Federal Machine & Welder Co. v. Commissioner

11 T.C. 952 · United States Tax Court · Nov 30, 1948

In Commissioner v. … Brown Lumber Co. v. Commissioner, 59 App. D. C. 110, 35 F. 2d 880 . Transfer of possession is also significant. Helvering v. Nibley Mimnaugh Lumber Co., 63 App. D. C. 181, 70 F. 2d 843 ; Commissioner v. Union Pac. R.

Brown Corp. of Ionia, Inc. v. Commissioner

45 T.C.M. 200 · United States Tax Court · Nov 29, 1982

The three agreements which Brown Corporation joined in were signed for it by Mr. Lampe in his capacity as its chairman of the board. Mr. … Lampe, acting as brown Corporation's chairman of the board, on that same date in turn *64 assigned the letter of credit to Mr. Coe.

Gilken Corp. v. Commissioner

10 T.C. 445 · United States Tax Court · Mar 17, 1948

In Sloan Shipyards Construction Co. v. Thurston Co., 111 Wash. 361 ; 190 Pac. 1015 , there was involved a contract to sell property to the Shipping Board, it to become owner upon payment. … Brown v. Helvering, 291 U. S. 198 .

BROWN v. COMMISSIONER

2004 T.C. Summary Opinion 45 · United States Tax Court · Apr 6, 2004

BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11482-02S. Filed April 6, 2004. David A. Brown, pro se. Marc L. Caine, for respondent. … Douponce v. Commissioner, T.C.

Crown Cork International Corp. v. Commissioner

4 T.C. 19 · United States Tax Court · Sep 21, 1944

August 8, 1939, to Brown, Harriman & Co. of London for the sum of $ 27,500, and the 20,000 shares of Crown Cork Co., Ltd., referred to in the above table on December 4, 1939, to Brown, Harriman & Co. of London for the sum … Because the Board's decision there under review had antedated Higgins v. *74 Smith and there were no ultimate findings on the issue as framed by the appellate court, the case was remanded for further proceedings.

Palmer v. Commissioner

52 T.C. 310 · United States Tax Court · May 26, 1969

Helvering v. Davis, 301 U.S. 619 (1937); Cain v. United States, 211 F. 2d 375 (C.A. 5, 1954). … Board of Education v. Barnette, 319 U.S. 624, 643 (1943). Congress has great latitude in formulating classifications within a taxing statute. Abney v. Campbell, 206 F. 2d 836 (C.A. 5, 1953).

BROWN v. COMMISSIONER

2002 T.C. Summary Opinion 91 · United States Tax Court · Jul 16, 2002

Summary Opinion 2002-91 UNITED STATES TAX COURT SONJA AND DAVID BROWN, Petitioners v. … Brown (petitioner) was employed by a furniture rental company, and Mrs. Brown was employed by the Department of Veterans Affairs, an agency of the United States.

BROWN v. COMMISSIONER

84 T.C.M. 135 · United States Tax Court · Aug 5, 2002

Memo. 2002-187 UNITED STATES TAX COURT JACQUELYN BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5978-00. … Petitioner is not entitled to relief for 1988 under section 6015 because the Browns’ 1988 tax liability was paid in full on May 18, 1998, which is before July 22, 1998. Miller v.

BROWN v. COMMISSIONER

2001 T.C. Summary Opinion 184 · United States Tax Court · Dec 12, 2001

BROWN, JR., AND KRISTI L. BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 225-01S. Filed December 12, 2001. Kelly Abreu, for petitioners. … Antonides v. Commissioner, supra; Ronnen v. Commissioner, 90 T.C. 74, 91 (1988); Fuchs v. Commissioner, 83 T.C. 79, 97-98 (1984); Dreicer v.

Specialty Paper & Board Co. v. Commissioner

24 T.C.M. 1085 · United States Tax Court · Jul 28, 1965

Specialty Paper and Board Co., Inc. v. Commissioner. Specialty Paper & Board Co. v. Commissioner Docket No. 189-63. United States Tax Court T.C. Memo 1965-208 ; 1965 Tax Ct. Memo LEXIS 122 ; 24 T.C.M. … Petitioner cites Tex-Penn Oil Co. v. Commissioner, 83 F. 2d 518 (C.A. 3, 1936), affd. sub nom. Helvering v. Tex-Penn Oil Co., 300 U.S. 481 (1937) and United States v.

Hyman v. Commissioner

1 T.C. 911 · United States Tax Court · Apr 13, 1943

As stated by the court in Brown v. Commissioner, 131 Fed. (2d) 640 (certiorari denied, 318 U. S. 767 , affirming 46 B. T. … Commissioner, 124 Fed. (2d) 772, in which the court said in reversing the Board: We think the Board erred in holding that the petitioner John Stuart was liable under Section 166 (2) of the Act, and from what we have said

Wanamaker Trustees v. Commissioner

11 T.C. 365 · United States Tax Court · Sep 27, 1948

Following Mead Corporation v. … The amounts in question must accordingly be regarded as having been in effect paid to Mary Brown Warburton and Rodman Wanamaker II, and in turn paid over by them to petitioners. Bergan v. Commissioner (C. C.